* for persons who have academic, socio-economie, or other handicaps that prevent them from succeeding in the regular vocational education program." (Italic supplied)

HEW calls such persons disadvantaged. The definition of "disadvantaged' for vocational education differs from the more common definitions used by HEW and the Department of Labor for other programs which define "disadvantaged" primarily on the basis of family income. For vocational education, HEW defines "disadvantaged" on the basis of a person's inability to succeed in the regular program without special assistance, such as might be provided by individual tutors, consultants, psychologists, instructional aides, diagnostie testing, modified or special programs, remedial education, and extension of the school day.

HEW does not consider all persons from low-income families to be neces sarily disadvantaged, because many students from such backgrounds can and do succeed in regular programs. Some State and local officials did not understand this requirement and apparently were confused by the different definitions of "disadvantaged" used for different programs. As a result, vocational education funds targeted for persons unable to succeed in regular prograшs without special assistance did not serve the purpose for which they were intended.

Of the $79.2 million in Federal funds made available to the four States for fiscal year 1970, $13.8 million, or 17 percent, was allotted to special programs for disadvantaged persons.

HEW sponsored meetings of school administrators and vocational educators in March and April 1969 to provide these officials with guidelines for defining "disadvantaged" persons and programs; these guidelines were published in booklet form in October 1969. In February 1970, HEW issued another instruetion, entitled “Suggested Utilization of Resources and Guide for Expenditures,” providing further guidance. In May 1970, manditory regulations were published in the Federal Register.

In essence, the HEW guidelines repeated the requirement of the act that the funds for disadvantaged students were to help persons unable to succeed in regular vocational programs and were to be used only to pay the costs of providing special programs, modifying existing programs, or furnishing supple mentary special services.

The State plans, approved by HEW for the four States, repeated the requirements of the law and HEW's instructions with little or no elaboration. Thee plans did not indicate what procedures would be used to insure that funds for the disadvantaged were properly used. If HEW had required the States to describe these procedures in their State plans and if the procedures were effectively followed, more of the funds might have been used to provide special programs or services to the disadvantaged. The descriptions could include the types of information local school districts would be required to provide to the States and the type and frequency of the State's monitoring of local districts.

CALIFORNIA

Of $4.9 million in Federal funds received for disadvantaged students in fiscal year 1970, California allocated $3.6 million to local school districts with the instruction-consistent with HEW's guidelines-that the funds be used for programs and services for persons who could not succeed in regular vocational programs without special assistance. The balance, $1.3 million, was allocated on the basis of written proposals from school districts, stating that funds were needed for specific programs for persons who could not succeed in the regular program.

To evaluate the State's administration of funds for the disadvantaged, we concentrated on the $3.6 million general allocation. In visiting several school districts, we found that local officials did not seem to be familiar with HEW's definition of "disadvantaged" persons and programs and did not follow the State's instructions to seek out those persons who could not succeed in the regular vocational program. In most instances, the programs funded under the general allocation were attended by regular students and did not provide special assistance for the disadvantaged. For example:

One school district in California claimed a total expenditure of $46.000 for the disadvantaged in 14 trade and industrial courses. We reviewed four of these 14 courses which district officials said had used funds for the disadvantaged. Instructors for the four courses told us that requirements

for enrollment in the courses would, if anything, probably prevent disadvantaged students from enrolling and that no special services for the disadvantaged were provided.

We reported our findings to the California State Director of Vocational Education, who told us that education programs for the disadvantaged lacked effective State and Federal direction. He said further that a review would be made in each school district in California to insure that all programs were in compliance with Federal criteria.

MICHIGAN

Although Michigan's written procedures for allocating funds for special programs for the disadvantaged also recognize the intent of the act and HEW's guidelines to identify and help persons who cannot succeed in the regular program, these procedures were not followed. In fiscal year 1970, Michigan made a general allocation of $860,000, or 35 percent of its $2.47 million in Federal funds intended for the disadvantaged, to local school districts to purchase equipment for their regular vocational education programs. The school districts were not told that the funds were to be used for the disadvantaged. State officials said that, although the equipment was for regular vocational programs, some disadvantaged students may have had the opportunity to use it. The remaining 65 percent-$1.61 million-was allocated on the basis of written proposals from local school districts requesting funds for special programs. Although the State required the proposals to contain information on the objectives and goals of the programs and criteria for student selection, many proposals were approved that did not contain this information. In visits to local school districts, we found that some programs approved for the disadvantaged were open to all students and were not designed to serve persons unable to succeed in the regular vocational program. For example:

For one school district, the State approved a "Business Education Exemplary Curriculum” project for $63,550. Students were eligible who attended one of two inner-city high schools in areas with poor socioeconomic populations and who had taken no previous high school business education courses. The local school officials responsible for the program said that no attempts were made to identify students who were disadvantaged. Rather, all students who had signed up for the traditional business courses were admitted into the new course.

State officials-explaining why they had made a general allocation of funds, intended for the disadvantaged, to purchase equipment for regular vocational programs said that the requests for equipment funds exceeded the amounts available for this purpose; therefore, funds for special programs had been used to partially meet this need. They explained further that these funds were distributed to school districts on the presumption that some people below poverty levels lived in the area and would use the equipment. In our opinion, these comments by State officials indicate a misunderstanding of the intent of the act and a lack of understanding of HEW's implementing guidelines.

State officials told us that, because of a lack of staff to adequately monitor local programs, they had not been aware of the violations but that in the future they would increase their monitoring activity.

OHIO

Ohio's procedures governing the use of vocational education funds for disadvantaged students recognize the intent of the act and HEW's guidelines to identify and help persons who cannot succeed in the regular program. However, the procedures were not always followed.

Fiscal year 1970 Federal funds for the disadvantaged-$2.67 million-were allocated to local school districts on the basis of written proposals. In our visits to selected local school districts, we found that the programs in operation were not the same as those described in the approved proposals. Persons participating in the programs were not necessarily disadvantaged, and often the programs were part of the regular vocational program. Further, local officials appeared to have misunderstood HEW's guidelines regarding the use of funds for disadvantaged persons. For example:

On May 4, 1970, the State approved $42,800 for equipment for an "Office Duplicating and Communication Specialist" course. The school officials acknowledged to us that the majority of students enrolled in the

course could not qualify as disadvantaged. They stated that, at the time of approval, they were not aware that the funds could be used only for specific persons who were unable to succeed in the regular programs and who required special assistance.

In discussing our findings, State officials told us that they understood the definition of "disadvantaged" as intended by the act but that they had not been aware that local districts did not have an adequate understanding of the purpose of the special funds. They said State monitoring had not disclosed this situation, because the State was slow in building up its monitoring staff. They said that an increased staff (recently expanded from one to three) and a new requirement (local school districts must submit information on each student served indicating the nature of the disadvantagement which made the student eligible) should prevent this situation from happening in the future.

PENNSYLVANIA

Pennsylvania allocated $3.69 million of its Federal vocational education funds in fiscal year 1970 for programs for disadvantaged students. Of this amount, $1.83 million was allocated to local school districts on the basis of a formula which took into consideration the total number of children in each district and the number of those from families on public assistance, in foster homes, and in institutions for the neglected or delinquent; $940,000 was allocated to the schools in the two largest cities in the State; and the remaining $920,000 was allocated on the basis of written requests from school districts for specific programs.

Pennsylvania's definition of "disadvantaged," consistent with the act and HEW's guidelines, includes persons who have academic, socioeconomic, cultural, or other handicaps. However, State officials have placed limited emphasis on the fact that, to be considered disadvantaged, such persons must be unable to succeed in regular vocational courses.

In specific programs conducted by selected local school districts, we found that this lack of emphasis resulted in the programs' being open to all persons and that only limited attempts were made to identify persons requiring special assistance. For example:

A large city school district received $884,899 for a vocational project. Part of this amount ($607,920) was designated as chargeable to the disadvantaged allocation, on the basis of the school district's estimate that 69 percent of the students in the project were disadvantaged. However, no attempts were made in the city high schools to identify specific students who could not succeed in the regular program.

State officials acknowledged that general allocations to schools with a large percentage of low-income or academically deficient students did not meet the intent of the act, and they attributed the improper allocations that occurred early in the program to an inexperienced staff. The officials pointed out, however, that the State had instituted improved controls-certifications by local school officials that programs funded by the general allocations contain disadvantaged students; evaluation reports showing numbers of students, achievements, and objectives met; and field visits by State personnel-to insure that funds for the disadvantaged reach those in need. State officials also told us that State personnel making field visits would seek to insure a better understanding of the objectives of the act.

HEW officials in the three regional offices responsible for the four States included in our review said that insufficient staff had prevented them from adequately monitoring the States' use of funds for the disadvantaged. They also said that they would place increased emphasis on the proper use of funds for the disadvantaged.

On July 19, 1971, we met with HEW headquarters officials to discuss our findings. They agreed that we had identified problems which demonstrated a lack of clear understanding of the requirements of the act and HEW's implementing guidelines.

On July 26, HEW issued a memorandum to the States reclarifying the intent of the act, stating in part that:

"The basic criterion for identification of a person for participation in a vocational education disadvantaged program is inability to succeed in the regular program without special assistance or services. *** Determination of 'inability to succeed in vocational education' is not a simple matter and may

well vary by instructional program and by State. Many criteria such as test scores, academic performance, or drop out, are indicators which may be used."

"In any case, the expenditures reported must relate specifically to individuals served and may not be a blanket application to an unidentified group or a pro rata share of a particular program cost. ・・・ States should immediately disseminate to local educational agencies the criteria used and other information necessary to develop uniform understanding of disadvantaged • pro

grams.

programs. Also which presents

This office is planning additional regional conferences to discuss and further clarify the procedures relating to disadvantaged available in the next few months will be a publication, various classifications and descriptions of categories of disadvantaged A revised version of the "Suggested Utilization of Resources and Guide to Expenditures" was published in July 1972. It provided extensive guidance on the proper use of Federal funds for the disadvantaged. This guidance, together with HEW's memorandum and the planned regional conferences, should provide the clarification needed. However, adequate program monitoring by HEW and the States is needed to insure implementation of the improved procedures.

RECOMMENDATIONS TO THE SECRETARY OF HEALTH, EDUCATION, AND WELFARE

The Secretary of HEW should instruct its regional offices to more closely monitor the use of Federal funds for special programs and services for the disadvantaged to insure that these funds are being used as intended by the act and HEW's implementing guidelines. HEW should also require the States to describe, in their State plans, the procedures they intend to employ to insure that funds for the disadvantaged are properly used.

AGENCY COMMENTS AND ACTIONS

The Assistant Secretary, Comptroller, agreed with our recommendations, stating that:

"One of the States studied has established stricter controls for local education agencies for use of disadvantaged funds. Regional staff are emphasizing to the other States the concerns reflected in the GAO study and are expanding monitoring activities."

Officials of the four States involved also agreed, although officials from one State complained that "no mention is made of programs that were in compilance with the technical definition of disadvantaged." We observed some programs that we believed met the intent of the act. But, as indicated above, the majority of programs reviewed did not meet this intent.

The actions promised or taken by HEW and the States should result in needed program improvements.

CHAPTER 4.-MANAGEMENT INFORMATION INCOMPLETE AND INACCURATE One of the major purposes of a management information system is to develop data on program operations and results that can be used to assess program effectiveness. The information on vocational education which the States are required to report to HEW is not adequate to evaluate program results. In addition, information submitted by the four States to meet HEW's requirements was often inaccurate or incomplete.

Because of dissatisfaction with the information required by HEW, two of the States and a county in a third State have started to develop their own systems so they will be better able to evaluate the results of their programs, The act (82 Stat. 1095) requires that the Commissioner of Education: ***・・ shall collect data and information on programs qualifying for assistance *** for the purpose of obtaining objective measurements of the effectiveness achieved in carrying out the purposes of such programs,"

In addition, HEW's implementing instructions (45 CFR_1024(J)) require that:

Evaluation of the results of the program of instruction will be made perfod.cally *** by the State *** and continuously on the local level with the results being used for necessary change or improvement in the program ***.”

BETTER INFORMATION NEEDED ON PROGRAM RESULTS

The information concerning program results which HEW required the States to report consisted of summaries of the number of students graduating with major training in each of 10 types of employment fields and their employment status about 4 months after graduation. The reports show the number of graduates (1) available for employment and, if unavailable, whether they are continuing their education, (2) unemployed, (3) employed in a job in, or related to, their vocational training field, and (4) whose employment status is unknown.

Comparable information has not been reported for nonvocational graduates: therefore, the comparative advantages of vocational education could not be adequately evaluated. Also, no information was reported on the graduates" status after the 4-month followup.

Officials in all four States criticized HEW's requirement for (1) followup data on all vocational graduates and (2) data only 4 months after graduation. Some said this time period was too soon after graduation to arrive at valid conclusions about the benefits of vocational education. Some said followup would be more meaningful if it were limited to a statistical sample of enrollees instead of including all enrollees as required by HEW. Such a sample would, they believe, permit more detailed data to be obtained on such items as type or job, initial and subsequent earnings, advancement, employees' job satisfaction. and employers' evaluations of the quality of the employees' vocational training. They suggested that data on the persons in the sample should be obtained periodically over a longer period after graduation-1 year, 5 years, or as long as 10 years after graduation.

Because of dissatisfaction with the HEW system, Ohio and Pennsylvania started implementing their own management information systems.

INACCURATE AND INCOMPLETE DATA

In three of the four States, we found that the enrollment data reported to HEW was inaccurate. (Ohio's computerized system provided accurate data.) Furthermore, in all four States the data reported on the status of vocational education graduates 4 months after graduation (e.g., employed, type of job, in college, etc.)-particularly in large cities-was often too incomplete to permit assessment of program results. All four States recognized the weaknesses and were taking steps to overcome them, e.g., Pennsylvania was also developing a computerized system for compiling the data.

The inaccuracies in enrollment data produced overstated enrollment and graduation figures which, in most cases, were caused by counting the enrollment in individual vocational classes rather than by counting the actual number of students enrolled. Those students taking more than one vocational course were counted more than once.

Incomplete followup data was caused by poor responses to questionnaires sent to vocational graduates. Although a 100-percent response is not usually expected or necessary, we noted response rates as low as 36 percent. According to a State official, a followup with this low rate of response is biased because only the better students respond.

A more intensive effort, consisting of additional mailings and personal contacts, would be necessary to bring the low response rates to a more acceptable level. Such efforts are expensive, but using a statistical sample could help to reduce this expense.

The Department of Labor's Manpower Administration has been experimenting with another technique for followup on graduates from its manpower programs. This technique involves the use of Social Security records for analyzing the graduates' earnings records. Although individuals' earnings records are highly confidential, analysis have been performed by the Social Security Administration for the Department and the overall results were provided to the Manpower Administration. The Department has determined that this system has considerable value in evaluating the results of programs designed to improve the employability and the earnings of the participants and is developing the system for general application to manpower programs.

We believe that HEW should consider the possibility of using statistical sampling, Social Security records, or a combination of the two in followup of graduates from vocational education.